Supported housing privacy notice

Portsmouth City Council is a registered Data Controller (Registration Number Z5578313). We aim to meet high standards when collecting and using personal information in line with data protection law. This privacy notice explains how we collect and use personal information when you receive services in our supported housing portfolio.

We may collect personal information about you from you, and sometimes from other organisations involved in your support. This may include:

• name, address and date of birth
• contact details
• next of kin / emergency contacts
• information about your household or relationships
• referral and assessment information
• relevant case information
• risk information (for example, information to help keep you or others safe)
• financial information (including bank account details where you pay by direct debit)
• photographs (only where needed and/or where you have agreed)
• special category information, where relevant to your support or tenancy management, such as:
  • ethnicity
  • NHS number
  • physical and mental health information
  • mental capacity information

We also keep copies of letters and records of telephone calls, along with other information we may receive about you from other people or organisations involved in your support.

We use personal information to:

• deliver supported housing services
• manage your tenancy
• manage planned and responsive repairs
• offer support and help you access other services
• manage payments linked to your tenancy or property (for example, utilities or service-related charges, where applicable)
• improve and develop services
• produce communications (for example, press releases) only where you have agreed

We use your personal information to:

• contact you when we need to about your home, tenancy or support
• take payments (for example, direct debit or card payments over the phone where applicable)
• coordinate with relevant internal teams and partner organisations to support you
• help you access other Portsmouth City Council services you may need

UK GDPR requires us to have a lawful basis to process your personal data. The lawful basis we rely on will depend on what we are doing with your information. ICO guidance explains that privacy information must include the purposes and lawful basis for processing.

In most supported housing cases, the legal basis is:

• Article 6(1)(e) – Public task: processing is necessary for us to perform a task in the public interest or in the exercise of our official authority (for example, delivering housing-related support and managing tenancies as a local authority).
• Article 6(1)(b) – Contract: processing is necessary for a contract (for example, your tenancy agreement and services delivered under it).

Where we use special category data (such as health, ethnicity, or mental capacity information), we must also meet an additional condition under Article 9. We use this information only where necessary for providing support, managing risks, and coordinating with relevant services involved in your care and housing needs.

Where we use your information for publicity/communications (for example, photos or case studies in press releases), we will only do so with your agreement and you can withdraw that agreement at any time (this won’t affect other parts of the service).

Some information is needed so we can provide supported housing services, manage your tenancy, and keep you and others safe. If you do not provide information that is necessary, we may not be able to:

• assess your needs or provide appropriate support
• manage your tenancy or respond to issues relating to your home
• coordinate with other services where this is required for safeguarding or risk management

We keep your personal data secure using technical and organisational security measures. Only staff who need access to personal data for their work are allowed to access it, supported by training and checks.

When organisations process personal data on our behalf (for example, repairs contractors), they are required by contract to keep it secure and use it only for the purposes set out by Portsmouth City Council.

There may be times when we need to share your information with other people or organisations. We will only share information where the law allows or requires us to, and only the minimum needed for the purpose.

This may include sharing information:

• in emergencies, safeguarding concerns, or life‑threatening situations
• for preventing or detecting crime or fraud, or where we have a statutory duty
• with organisations involved in your support or housing management

The current supported housing notice lists the types of organisations we may share with, including: health agencies, Department for Work and Pensions, police, care agencies, city/district/borough councils, direct payment support services, internal Portsmouth City Council departments, and repairs contractors (where relevant).

We may withhold information where sharing it would place someone at risk or where the law restricts disclosure.

We do not keep personal information for longer than necessary. Retention periods depend on the type of record. The supported housing notice currently signposts that full retention information is available on the council website.

You have rights over your personal data, including the right to request a copy of the information we hold about you. This is called a Subject Access Request (SAR).

Depending on the circumstances, you may also have rights to:

• ask us to correct inaccurate information
• ask us to restrict how we use your information
• object to certain types of processing (where applicable)
• ask for deletion of information (where applicable — this does not apply where we must keep information to meet legal duties or for official functions)
• withdraw consent where we rely on consent (for example, optional publicity/communications)

To make a SAR, use the details in How to contact us below or use the Council’s Freedom of Information routes referred to in the existing notice.

If CCTV or body worn camera images are stored and catalogued, individuals can request access by making a Subject Access Request. The current supported housing notice explains that CCTV may not be recorded at all locations and access may be restricted where images include other identifiable people or where disclosure would be unlawful (for example, due to crime prevention considerations).

We do not use your information to make decisions about you based solely on automated processing (without human involvement) for supported housing services.

We do not routinely transfer your personal data outside the UK. If we ever need to do so, we will ensure appropriate safeguards are in place as required by data protection law.

If you have a complaint or query about how we collect and use personal information, if you would like a change made to your record, or want to object to processing of your information, please contact us using the details below.

If you are not satisfied with our response, you can complain to the Information Commissioner’s Office (ICO):

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113

Data Protection Officer
Portsmouth City Council
Civic Offices,
Portsmouth,
PO1 2AL

Email: DataProtection@portsmouthcc.gov.uk

Telephone: 023 9282 2251

This privacy notice was last updated on 8 August 2025. It may be updated to reflect changes in law or service delivery.